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Notice of Public Comment Period - Draft Air Quality Permits 7285-7287 - Howard University

Friday, November 13, 2020

PUBLIC NOTICE

Draft Air Quality Permits 7248 through 7252, Howard University, Construction and Operation of a Combined Heat and Power System and Two 62.77 MMBTU/hr dual fuel-fired boilers at 2240 6th Street NW

Notice is hereby given that, pursuant to 20 DCMR §210, the Air Quality Division (AQD) of the Department of Energy and Environment (DOEE), located at 1200 First Street NE, 5th Floor, Washington DC, intends to issue Permit Nos. 7285 through 7287 to Howard University, to construct and operate a combined heat and power (CHP) system and supplemental boiler plant with 69.51 MMBtu/hr natural gas-fired combustion turbine generator (6.5 MWe) with a heat recovery steam generator with 26.5 MMBtu/hr natural gas-fired duct burners and as back-up, two 62.77 MMBtu/hour dual fuel-fired (natural gas as primary and ultra-low sulfur diesel (ULSD) as back-up fuel) boilers, located  at Howard University (HU), 2240 6th Street NW, Washington DC. The contact person for the facility is Tashni-Ann Dubroy, Ph.D., Executive Vice President and Chief Operating Officer, Howard University, phone number: (202) 806-2258.

The following units are to be permitted:

Emission Unit

Unit ID

Chapter 2 Permit

Heat Input Capacity (MMBtu/hr)

Primary Fuel

Secondary Fuel

Combustion Turbine-Generator

CTG-1

7287

69.51

Natural Gas

--

Heat Recovery Steam Generator

HRSG-1

26.5

Natural Gas

--

Boiler

CU-24

7285

62.77

Natural Gas

 ULSD

Boiler

CU-25

7286

62.77

Natural Gas

ULSD

Emergency Generator

EG-48

7048-SC-0175-R1

2,206 BHP

ULSD

--

This emergency generator set was permitted under a separate permitting action, but is considered part of the project for regulatory purposes and included in the emissions estimate below.

 

Emissions:

Based on the emission calculations provided by the facility, the units (including a separately permitted emergency generator set) have the potential to emit the following:

                                                   

Pollutant

Maximum Annual Emissions

(tons/yr)

Total Particulate Matter (PM Total)

10.69

Sulfur Dioxide (SO2)

2.92

Nitrogen Oxides (NOx)

25.64

Volatile Organic Compounds (VOC)

5.35

Carbon Monoxide (CO)

29.70

The proposed emission limits are as follows for the CHP plant:

a.   The CHP plant shall not emit pollutants in excess of the following [20 DCMR 201]:

Pollutant

Emission Limits (lb/MMscf)

Oxides of Nitrogen (NOx)

7.67

Carbon Monoxide (CO)

9.34

Volatile Organic Compounds (VOC)

3.34

Total Particulate Matter [PM(total)]†

14.08

      PM Total includes both filterable and condensable fractions.

Note that the PM limit is a streamlined requirement. The requirements of 20 DCMR 201 are more stringent than the requirements of 20 DCMR 600.1. Compliance with this condition will ensure compliance with both requirements.

b.   Visible emissions shall not be emitted into the outdoor atmosphere from the CHP plant, except that discharges not exceeding forty percent (40%) opacity (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minute period and for an aggregate of twelve (12) minutes in any twenty-four hour (24 hr.) period during start-up, cleaning, adjustment of combustion controls, or malfunction of the equipment [20 DCMR 606.1]

  1. The Permittee shall not burn in the unit any fuel that contains total potential sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input. [40 CFR 60.4330(a)(2)]

d.   NOx emissions from the CHP plant shall not exceed 2 ppmvd corrected to 15% oxygen (O2) as determined by testing performed pursuant to Condition IV(d). [40 CFR 60.4320, 20 DCMR 201, and 20 DCMR 805.4 (a)(1)(A)(i)] Note that this is a streamlined emission rate limit, and is more stringent than the limits found in 40 CFR 60, Subpart KKKK and 20 DCMR 805.4 for NOx emissions cited above. Compliance with this condition will ensure compliance with all three requirements.

e.   An emission into the atmosphere of odorous or other air pollutants from any source in any quantity and of any characteristic, and duration which is, or is likely to be injurious to the public health or welfare, or which interferes with the reasonable enjoyment of life or property is prohibited. [20 DCMR 903.1


The proposed emission limits are as follows for the boilers:

    1. Each of the boilers CU-24 and CU-25 shall not emit pollutants in excess of the following [20 DCMR 201]:

Pollutant

Emissions Burning Natural Gas (lb/hr)

Emissions Burning ULSD (lb/hr)

Oxides of Nitrogen (NOx)

0.70

5.71

Carbon Monoxide (CO)

2.35

2.48

Oxides of Sulfur (SOx)

0.19

0.13

Total Particulate Matter [PM(total)]

0.44

0.73

      PM Total includes both filterable and condensable fractions.

b.   Visible emissions shall not be emitted into the outdoor atmosphere from the boilers, except that discharges not exceeding forty percent (40%) opacity (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minute period and for an aggregate of twelve (12) minutes in any twenty-four hour (24 hr.) period during start-up, cleaning, adjustment of combustion controls, or malfunction of the equipment [20 DCMR 606.1]

c.   In addition to the requirements of Condition II(b), the boilers shall not emit any gases into the atmosphere of gases that exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. This standard applies at all times except during periods of startup, shutdown, or malfunction. [20 DCMR 205 and 40 CFR 60.43c(c) and (d)]

d.   Total suspended particulate matter (TSP) emissions from each of the boilers shall not be greater than 0.07 pounds per million BTU. [20 DCMR 600.1].

e.   NOx and CO emissions shall not exceed those achieved with the performance of annual combustion adjustments on each boiler. To show compliance with this condition, the Permittee shall, each calendar year, perform adjustments of the combustion processes of the boilers with the following characteristics [20 DCMR 805.8(a) and (b)]:

1.   Inspection, adjustment, cleaning or replacement of fuel burning equipment, including the burners and moving parts necessary for proper operation as specified by the manufacturer;

2.   Inspection of the flame pattern or characteristics and adjustments necessary to minimize total emissions of NOx and, to the extent practicable, minimize emissions of CO;

3.   Inspection of the air-to-fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer; and

4.   Adjustments shall be made such that the maximum emission rate for any contaminant does not exceed the maximum allowable emission rate as set forth in Condition II of this permit.

f.    An emission into the atmosphere of odorous or other air pollutants from any source in any quantity and of any characteristic, and duration which is, or is likely to be injurious to the public health or welfare, or which interferes with the reasonable enjoyment of life or property is prohibited. [20 DCMR 903.1]


The applications to operate the units and the draft permits and supporting documents are available for public inspection at AQD and copies may be made available between the hours of 8:15 A.M. and 4:45 P.M. Monday through Friday. Interested parties wishing to view these documents should provide their names, addresses, telephone numbers and affiliation, if any, to Stephen S. Ours at (202) 535-1747.


Interested persons may submit written comments or may request a hearing on this subject within 30 days of publication of this notice. The written comments must also include the person’s name, telephone number, affiliation, if any, mailing address and a statement outlining the air quality issues in dispute and any facts underscoring those air quality issues. All relevant comments will be considered in issuing the final permits.

 

Comments on the proposed permits and any request for a public hearing should be addressed to:


Stephen S. Ours  
Chief, Permitting Branch - Air Quality Division

Department of Energy and Environment
1200 First Street NE, 5th Floor
Washington, DC 20002


[email protected]

 

No comments or hearing requests submitted after December 14, 2020 will be accepted.

For more information, please contact Stephen S. Ours at (202) 535-1747.